JOINT MOTION TO DISMISS WITH PREJUDICE

!
Kate Gosselin,


! Plaintiff
vs.

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF PENNSYLVANIA

• :  !
  
• :  Docket No. 13:4989
  : :
  
• :  NOTICE OF VOLUNTARY DISMISSAL :
  

Case 5:13-cv-04989-JLS Document 22 Filed 11/27/13 Page 1 of 2

!Jon Gosselin, et. al. :

!

!
!
Pursuant to Fed. R. Civ. P. 41(a)(1)(A)(i), the plaintiff, Kate Gosselin, hereby voluntarily dismisses the above matter, without prejudice, as the opposing parties have not served an answer or a motion for summary judgment.

Defendants :

Date: November 27, 2013
! ! ! ! ! !

/S/ ______________________________ A. Jordan Rushie
2424 East York Street, Suite 316
 Philadelphia, PA 19125
Tel: (215) 385-5291
E-mail: Jordan@FishtownLaw.com

Respectfully Submitted,

!

Mulvihill & Rushie, LLC

!

!

Case 5:13-cv-04989-JLS Document 22 Filed 11/27/13 Page 2 of 2

Dated: November 27, 2013

!

Certificate of Service

I, A. Jordan Rushie, Esquire, served this notice of voluntary dismissal upon the following parties:

James P. Golden Hamburg & Golden, P.C. 1601 Market Street, Suite 3310 Philadelphia, PA 19103
 

Case 5:13-cv-04989-JLS Document 18 Filed 11/19/13 Page 1 of 2

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF PENNSYLVANIA
KATE GOSSELIN, ) ) Plaintiff, )

• )  CIVIL ACTION v. )
  
• )  NO.: 13:4989 JONATHAN K. GOSSELIN, ROBERT )
  HOFFMAN, and JOHN AND JANE DOES ) 1-20 ) ) Defendants. )
  JOINT MOTION TO DISMISS WITH PREJUDICE
  Plaintiff Kate Gosselin, by and through her attorney, A. Jordan Rushie, and Defendant Jonathan K. Gosselin, by and through his attorneys, BrittonTuma and Orwig Law Offices, files this Joint Motion to Dismiss with Prejudice pursuant to Federal Rule of Civil Procedure 41(a) and (c) and in support thereof, state as follows:
  Plaintiff Kate Gosselin agrees to dismiss with prejudice all claims and potential claims that she has or may have against Defendant Jonathan K. Gosselin that were or could have been asserted in this case.
  By this motion, Plaintiff Kate Gosselin is not dismissing her claims against any Defendant other than Defendant Jonathan K. Gosselin.
  Defendant Jonathan K. Gosselin agrees to dismiss with prejudice all counterclaims or potential counterclaims that he has or may have against Plaintiff Kate Gosselin that were or could have been asserted in this case.
  Dismissal with prejudice of the claims and/or counterclaims between Plaintiff Kate
  Gosselin and Defendant Jonathan K. Gosselin is appropriate pursuant to Federal Rule of Civil
  Procedure 41(a) and (c).
  JOINT MOTION TO DISMISS WITH PREJUDICE PAGE 1
  

Case 5:13-cv-04989-JLS Document 18 Filed 11/19/13 Page 2 of 2

WHEREFORE, Plaintiff Kate Gosselin and Defendant Jonathan K. Gosselin agree that an order dismissing the asserted and potential claims and counterclaims between them with prejudice is appropriate and respectfully request that the Court enter such order.

Dated: November 19, 2013

Respectfully submitted,
/s/ A. Jordan Rushie
2424 E York Street, Suite 316 Philadelphia, PA 19125
p. 215.385.5291
Attorney for Kate Gosselin
/s/ Shawn E. Tuma
Shawn E. Tuma BrittonTuma
7161 Bishop Road, Suite 220 Plano, Texas 75024
d. 469.635.1335
f. 972.767.3181
e. stuma@brittontuma.com
Richard L. Orwig (Associate Counsel) Orwig Law Offices
2213 Quarry Dr., Suite B001
West Lawn, PA 19609
p. 610.898.9880
f. 610.898.1323
e. rlorwig@orwiglaw.com
Attorneys for Jonathan K. Gosselin
CERTIFICATE OF SERVICE

The undersigned hereby certifies that a true and correct copy of the foregoing has been served via ECF upon all counsel of record in the above-styled civil action on November 19, 2013.
/s/ Shawn E. Tuma Shawn E. Tuma

JOINT MOTION TO DISMISS WITH PREJUDICE

PAGE 2 

Case 5:13-cv-04989-JLS Document 18-1 Filed 11/19/13 Page 1 of 2

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF PENNSYLVANIA
KATE GOSSELIN, ) ) Plaintiff, )

• )  CIVIL ACTION v. )
  
• )  NO.: 13:4989 JONATHAN K. GOSSELIN, ROBERT )
  HOFFMAN, and JOHN AND JANE DOES ) 1-20 ) ) Defendants. )
  ORDER GRANTING JOINT MOTION TO DISMISS WITH PREJUDICE
  After considering Plaintiff Kate Gosselin and Defendant Jonathan K. Gosselin’s Joint Motion to Dismiss with Prejudice, the Court GRANTS the Joint Motion to Dismiss with Prejudice.
  It is hereby ORDERED, ADJUDGED, AND DECREED that all claims and potential claims that Plaintiff Kate Gosselin has or may have against Defendant Jonathan K. Gosselin that were or could have been asserted in this case are hereby DISMISSED WITH PREJUDICE.
  It is hereby ORDERED, ADJUDGED, AND DECREED that all counterclaims or potential counterclaims that Defendant Jonathan K. Gosselin has or may have against Plaintiff Kate Gosselin that were or could have been asserted in this case are hereby DISMISSED WITH PREJUDICE.
  This Order does not apply to Plaintiff Kate Gosselin’s claims against any Defendant other than Defendant Jonathan K. Gosselin.
  

SIGNED on November ___, 2013.

Jeffrey L. Schmehl, U.S.D.J.

Case 5:13-cv-04989-JLS Document 18-1 Filed 11/19/13 Page 2 of 2

By agreement of the undersigned counsel:
/s/ A. Jordan Rushie
2424 E York Street, Suite 316 Philadelphia, PA 19125
p. 215.385.5291
Attorney for Kate Gosselin
/s/ Shawn E. Tuma
Shawn E. Tuma BrittonTuma
7161 Bishop Road, Suite 220 Plano, Texas 75024
d. 469.635.1335
f. 972.767.3181
e. stuma@brittontuma.com Attorneys for Jonathan K. Gosselin